Ruby Kumari Gupta Vs the State of Jharkhand through the Chief Secretary — Jharkhand HC (2026) — LawSathi Research

Ruby Kumari Gupta Vs the State of Jharkhand through the Chief Secretary — Jharkhand HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Dismissed

Issue for consideration

Whether the change in the answer key for question ID no. 170440 — an answer taken to be correct by three answer keys after verification by three different expert committees — was arbitrary. +4 more

Court's answer

Having examined the two disputed questions (question IDs 170440 and 170482) and the key answers at the appellant's counsel's persuasion, the Court finds no case to deviate from the opinion expressed by no less than three expert committees; not being domain experts, it holds this is not a case where the expert opinion is demonstrably wrong or manifestly arbitrary so as to warrant interference.

Ratio / Principle

The plea of malafides against the Jharkhand Staff Selection Commission, the domain experts and the examining agency fails: the pleadings are woefully lacking and nothing on record remotely shows malafides; the record that the appellant secured 288 marks out of 300 while the last selected candidate secured 290 negates the charge.

Key takeaways

No case is made out warranting interference with the learned Single Judge's order; the Division Bench adopts the reasoning in paragraphs 9, 10 and 11 of the impugned order and is not persuaded to take a different view.ratio¶28
Endorsing the Supreme Court's dicta in Ran Vijay Singh and Shubham Pal — presumption of correctness of key answers, benefit of doubt to the examination authority, no role for sympathy or compassion, and deference to domain experts — this Court holds that the learned Single Judge's approach is entirely consistent with the approach directed in a catena of Supreme Court decisions.ratio¶50

Detailed headnote1 paragraphs

L.P.A. No. 346 of 2025, High Court of Jharkhand at Ranchi (Coram: Chief Justice M.S. Sonak and Justice Rajesh Shankar; decided 12.02.2026). The Division Bench dismisses the appellant's letters patent appeal, affirming the learned Single Judge's order dated 28.04.2025 dismissing W.P.(C) No. 1487 of 2024, which challenged two answer keys (Question IDs 170440 and 170482) in the Jharkhand Staff Selection Commission's examination for Post Graduate Trained Teacher posts. The plea of malafides against the Commission, the domain experts and the examining agency is rejected as woefully lacking — the appellant secured 288/300 against a last-selected cut-off of 290. Endorsing Ran Vijay Singh v. State of U.P., (2018) 2 SCC 357, and Shubham Pal v. SSC (Civil Appeal arising out of S.L.P.(C) No. 21999 of 2024, decided 03.02.2026), the Court holds that interference with answer keys must be rare and confined to palpable mistakes; correctness of key answers is to be presumed, benefit of doubt goes to the examination authority, and academic matters are left to domain experts — here, objections were invited and at least 3 to 4 expert committees finalised the keys. The claim to the 14th position via the horizontally reserved female seat in the EBC-I category is rejected as irrelevant: marks cannot be arbitrarily increased to fill a reserved post, and two female candidates with higher marks were already recommended among the 13 selected. Appeal dismissed with no costs; pending interlocutory applications disposed of.

Issues for consideration

5 issues framed by the court

AI extract

1.
Whether the change in the answer key for question ID no. 170440 — an answer taken to be correct by three answer keys after verification by three different expert committees — was arbitrary.¶20
The court held
Having examined the two disputed questions (question IDs 170440 and 170482) and the key answers at the appellant's counsel's persuasion, the Court finds no case to deviate from the opinion expressed by no less than three expert committees; not being domain experts, it holds this is not a case where the expert opinion is demonstrably wrong or manifestly arbitrary so as to warrant interference.ratio¶58
2.
Whether the appellant was entitled to full marks for question ID No. 170482 on the contention that three options are correct as per the textbooks of H.L. Ahuja and B.K. Jhingan.¶21
3.
Whether the conduct of the Jharkhand Staff Selection Commission, the domain experts, or the agency conducting the examination was vitiated by malafides.¶24
The court held
The plea of malafides against the Jharkhand Staff Selection Commission, the domain experts and the examining agency fails: the pleadings are woefully lacking and nothing on record remotely shows malafides; the record that the appellant secured 288 marks out of 300 while the last selected candidate secured 290 negates the charge.ratio¶27
4.
Whether the appellant, a female candidate, was entitled to appointment against the 14th position because a seat was horizontally reserved for a female candidate in the EBC-I category and (per the appellant) no female candidate had been recommended.¶22
The court held
The contention based on the unfilled horizontally reserved female seat in the EBC-I category is irrelevant: marks cannot be arbitrarily increased merely to ensure that at least one candidate is selected to fill a reserved post, the rules or procedures do not contemplate or permit such an exercise, and such a fact can never be a relevant consideration.ratio¶55
5.
Whether the Division Bench should interfere with the learned Single Judge's order / with the expert-finalised answer keys, applying the principles in Ran Vijay Singh and Shubham Pal on re-evaluation and judicial interference with examinations.¶28
The court held
No case is made out warranting interference with the learned Single Judge's order; the Division Bench adopts the reasoning in paragraphs 9, 10 and 11 of the impugned order and is not persuaded to take a different view.ratio¶28